Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
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